State of Washington v. Eric Sean Roloson

CourtCourt of Appeals of Washington
DecidedOctober 8, 2024
Docket56823-3
StatusUnpublished

This text of State of Washington v. Eric Sean Roloson (State of Washington v. Eric Sean Roloson) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Washington v. Eric Sean Roloson, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

October 8, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

STATE OF WASHINGTON, No. 56823-3-II

Respondent,

v.

ERIC SEAN ROLOSON, UNPUBLISHED OPINION

Appellant.

VELJACIC, A.C.J. — Eric S. Roloson pled guilty to two counts of rape of a child in the first

degree. As part of the plea agreement, the State agreed to recommend a special sex offender

sentencing alternative (SSOSA). The trial court rejected the recommendation and imposed a

standard range sentence. Roloson appeals, contending that the State breached the plea agreement

by nominally recommending a SSOSA and then raising aggravating facts to persuade the court not

to impose a SSOSA. He also contends he should be permitted to withdraw his guilty pleas because

they were involuntary. Roloson lastly contends that the court erred by imposing a $500 victim

penalty assessment (VPA), a $100 deoxyribonucleic acid (DNA) collection fee, and a $100

domestic violence assessment. We affirm Roloson’s convictions, but remand for the trial court to

strike the VPA and DNA collection fee and reconsider the domestic violence assessment.

FACTS

Following allegations in January 2020 of sexual abuse involving Roloson and his

stepdaughters, Roloson left for Hawaii. He was arrested in August 2020 and brought back to 56823-3-II

Washington in October 2020.1 The State charged him with two counts of rape of a child in the

first degree and two counts of child molestation in the first degree. All crimes included a special

allegation of domestic violence.

Roloson agreed to plead guilty to two counts of rape of a child in exchange for the State

dropping the molestation charges and recommending a SSOSA. It was the parties’ understanding

that the victims also endorsed a SSOSA for Roloson.

At the plea hearing, the trial court informed Roloson of the standard sentencing range on

both charges and that both counts were subject to the Indeterminate Sentencing Review Board.

Roloson expressed no reservations. The court also informed him that it was aware of the parties’

joint recommendation for a SSOSA, but the court did not have to follow that recommendation and

instead it could impose a sentence anywhere within the standard sentencing range. Roloson stated,

“I do understand that, Your Honor.” Rep. of Proc. (RP) at 19. Roloson then pled guilty to two

counts of rape of a child in the first degree. The court ordered a presentencing investigation report

(PSI).

The PSI indicated that the girls’ mother and one of the girls “initially agreed that a SSOSA

sentence was appropriate, but that they do not want that now.” Clerk’s Papers (CP) at 21. The

PSI also indicated that the mother reported that “[t]he girls have a life sentence dealing with what

happened to them. [Roloson] should have a life sentence in prison because you can’t take it back.”

CP at 21. Based on the victims’ statements, Roloson’s statements, and a risk assessment, the PSI

recommended that Roloson receive a standard range sentence.

1 The delay in returning to Washington was because Roloson was incarcerated in Hawaii and, while in custody, he was attacked by other inmates. His injuries were significant, resulting in a lengthy hospital stay and ultimately delaying commencement of proceedings in Washington.

2 56823-3-II

At the 2022 sentencing hearing, the State began by stating that there was an agreed

recommendation for a SSOSA. The State then addressed the somewhat inconsistent statements

from the victims in the PSI about initially supporting a SSOSA but then appearing to change their

minds. The State explained that it had been a long and difficult process for them in part because

Roloson “took flight to Hawaii,” was brought back to Washington in October 2020, and the matter

had been pending ever since. RP at 36.

The State went on to explain that it described the sentencing recommendation alternatives

with the victims and they agreed a SSOSA would be best, and most importantly, they wanted

finality. The State clarified that the girls and their mother “did support the SSOSA. They still do

support the SSOSA, but as with everything in life, there are conflicts. And they’re—they’re just

normal people who have had a really bad thing happen to them, and they have some conflicts.

They’re going to have an opportunity to express that to Your Honor.” RP at 36-37.

The girls’ mother spoke at the sentencing hearing. She told the trial court that she

supported the plea agreement, including a SSOSA recommendation, to prevent her daughters from

having to testify and relive Roloson’s horrendous actions. She further stated that she had “fears

that if he is released into the community, he will recommit these horrendous crimes. Repeating

the same actions of molesting, raping, physically and mentally abusing my family. . . . I do fear

[Roloson] will try to come after us if he is released.” RP at 41. She requested that if the court

decided to impose a SSOSA that Roloson not be permitted to “be released into Cowlitz County.

The thought of him living in the same town as us is completely devastating.” RP at 41.

The girls also made statements at the sentencing hearing. One told the trial court that “[t]he

only reason I chose to let him have the SSOSA deal was because I was scared of facing him in

trial.” RP at 43. The other girl stated, “I fear that if proper action isn’t taken, that others may be

3 56823-3-II

hurt and abused by [Roloson].” RP at 47. She asked the court to take into consideration “the

safety of our community.” RP at 47.

Roloson then interjected that the sentencing hearing must stop because he was going to file

a motion to withdraw his guilty pleas. The trial court stopped the sentencing hearing and allowed

briefing on the motion to withdraw the guilty pleas.

Roloson argued that he wanted to withdraw his guilty pleas on the basis that his pleas were

not knowing, intelligent, and voluntary because the State breached the plea agreement. Roloson

claimed that he only took the plea agreement because of the State’s assurances that the victims

would support a SSOSA and it appeared that was not the case at the sentencing hearing. Roloson

claimed he was “bombarded” and that the plea agreement was “undercut” in a way that created a

manifest injustice. RP at 67-68.

The State responded that it satisfied its obligation under the plea agreement by

recommending a SSOSA and that the victims expressed their desire for a SSOSA even though they

had concerns about Roloson in the community. The State further argued that there was no breach

because it could not control what the victims would say and that the victims were not parties to the

plea agreement. The State commented that it appeared defense counsel was implying that Roloson

“only admitted behavior in order to get this deal and not that he was actually admitting to the

behavior. That’s a problem.” RP at 71.

In an affidavit in support of its memorandum opposing Roloson’s motion to withdraw the

guilty plea, the prosecutor stated that the PSI caused him “some concern” based on both Roloson’s

and the victims’ statements so he met with the girls and their mother after the PSI and felt satisfied

that they “remained supportive” of a SSOSA. CP at 136-37.

4 56823-3-II

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